The present application relates to semiconductors, and more specifically, to techniques for forming semiconductor structures. Memory cells for computer memory may be formed using semiconductor fabrication processes. Dynamic random-access memory (DRAM) cells are fast and expend little power, but have to be refreshed many times each second and require complex structures to incorporate a capacitor in each DRAM cell. Flash type electronically erasable programmable read-only memory (EEPROM) cells are nonvolatile, have low sensing power, and can be constructed as a single device, but take microseconds to write and milliseconds to erase, which may be too slow for some applications. Magnetic memory cells store information as the orientation of magnetization of a ferromagnetic region, and can hold stored information for long periods of time and are thus nonvolatile. Magnetoresistive (MR) memory cells are a type of magnetic memory cell that uses the magnetic state to alter the electrical resistance of materials near the ferromagnetic region. An array of MR memory cells is referred to as magnetic random-access memory (RAM) or magnetoresistive random-access memory (MRAM).